HMDA reporting exemptions include temporary financing (e.g., bridge loans, construction-only loans), loans on unimproved land, unsecured home improvement loans, and loans purchased by an institution acting in a fiduciary capacity. Other exclusions include agricultural-purpose loans, reverse mortgages, and loans under $500.
The following transactions are not required to be reported under Regulation C:
Lien Status
The bank should not report unsecured home purchase loans under HMDA because such loans are not secured by a dwelling. The definition of home purchase loan in §203.2(h) is a loan secured by and made for the purpose of purchasing a dwelling.
Banks, credit unions, and savings institutions with less than $50,000,000 in total assets remain exempt from HMDA regardless of loan origination volume.
Construction loans that are excluded from HMDA reporting requirements are a) loans to homeowners that will be replaced with permanent financing through a refinance of the construction loan when the home is completed (Examples 3 and 4), and b) speculative construction loans that will be paid off through the sale of the ...
A closed-end business-purpose loan used to purchase and improve a multi-family dwelling is typically not subject to the same reporting requirements as consumer loans. This is because it is for a business purpose rather than personal, family, or household use.
Home purchase loans, home improvement loans, and refinancing loans are all types of loans that apply to HMDA reporting requirements. The loan must also be either an open-end line of credit or a closed mortgage loan to qualify for HMDA reporting.
What does Regulation Z not cover?
Seven common types of loans include Personal Loans, Auto Loans, Student Loans, Mortgage Loans, Home Equity Loans, Payday Loans, and Debt Consolidation Loans, each serving different financial needs, from major purchases like cars and homes to consolidating debt or managing unexpected expenses.
The final rule increases the asset threshold for calendar year 2026 HMDA data collection and reporting to $59 million. As a result, banks, savings associations, and credit unions with assets of $59 million or less as of December 31, 2025, are exempt from collecting and reporting HMDA data for 2026 activity.
Beginning on January 1, 2022, a financial institution originating 200 or more open-end lines of credit must collect, record, and report HMDA data for open-end lines of credit.
HMDA applies to open-end and closed-end credit secured by a dwelling. Business purpose loans are generally exempt; however if the loan is for home-improvement, home purchase or refinance the loan is reportable. For example, if a dwelling secured business purpose loan is refinanced, the refinance is HMDA reportable.
TILA requirements do not apply to the following types of loans or credit: Credit extended primarily for business, agricultural, or commercial purposes. Credit extended to an entity rather than a natural person, with limited exceptions for certain trusts.
First, reporting originations such as FHA- insured loans is more straight-forward than reporting secondary market purchases. As discussed earlier, lenders may report originations such as FHA-insured loans to HMDA but fail to report the secondary market disposition of those originations.
This means you'll have more time to repay the loan and build equity in your property. Additionally, because multi-family loans are considered commercial financing, they may be eligible for certain tax breaks that aren't available with other types of loans. There are some potential drawbacks to consider as well.
The 4 Cs of lending are Capacity, Capital, Credit, and Collateral, a framework lenders use to assess a borrower's creditworthiness by evaluating their ability to repay a loan, their existing financial reserves, their credit history, and the assets securing the loan, respectively. These factors help lenders gauge risk, making it easier for borrowers with strong profiles to get approved for mortgages and other loans.
While loans have many categories, the three fundamental types often distinguished by purpose and security are Personal Loans (flexible, often unsecured), Mortgages (for property, secured by the home), and Auto Loans (for vehicles, secured by the car), with other common types including Student Loans, Business Loans, and Home Equity Loans. Loans are also categorized by structure (secured vs. unsecured, open-ended/credit line vs. closed-ended/installment) or term (short, intermediate, long).
Plan 2 loans are those taken out for undergraduate courses and Postgraduate Certificates of Education (PGCE) since 1 September 2012 in Wales and between 1 September 2012 and 31 July 2023 in England. Postgraduate/plan 3 loans are those taken out for master's or doctoral courses by borrowers in England and Wales.
However, several types of credit fall outside Regulation Z's scope. Business loans, commercial credit, agricultural loans, federal student loans, and loans for public utility services are generally exempt.
Reverse Mortgages and HOEPA Exemptions
Reverse mortgages are exempt from HOEPA coverage. These loans work differently than standard mortgages. Instead of making monthly payments, borrowers—usually seniors—borrow against the equity in their homes and repay the loan when the house is sold or they move out.
Annual threshold adjustments. Based on the CPI-W in effect as of June 1, 2025, the exemption threshold will increase from $71,900 to $73,400, effective Jan. 1, 2026.
Thus, a financial institution must collect, record, and report data for dwelling-secured, business-purpose loans and lines of credit that are home improvement loans, home purchase loans, or refinancings if no other exclusion applies.
Identifying HMDA Reportable Transactions
Generally speaking, unless a transaction is expressly excluded under 12 C.F.R. §1003.3(c), an institution subject to HMDA must report all consumer closed‑end mortgage loans and open-end lines of credit secured by a dwelling.
Although the small business lending rule has an exclusion for HMDA-reportable loans, transactions used primarily for agricultural purposes are not 'covered loans' under Regulation C. Thus, they cannot be excluded from the small business lending rule as HMDA-reportable loans, even if they are secured by a dwelling.